Wanamaker v. Philadelphia School District

Opinion by

Mr. Justice Eagen,

The sole question presented by this appeal is whether the Business Use and Occupancy Tax of Philadelphia, imposed on the use or occupancy of real estate for commercial or industrial activity, is an unequal tax on real estate and thus violates the Uniformity Clause of the Pennsylvania Constitution.1 We hold today that the tax in question is a valid privilege tax on the use of such real estate and, hence, is in no sense violative of the uniformity provision.

The facts and history of the case may be summarized as follows:

On June 4, 1970, the Council of the City of…